(63) "Dangerous Goods List" is appropriate for IMDG Code as pointed out by Canada.
Re: Section 12.1 and 12.2
UK Comment No.22
(64) I agree with the comments by the coordinator and by the UK on the headings.
Re: Section 12.2.3
(65) I agree with the amalgamation of previous 12.2.3 and 12.2.4 as proposed by Germany.
Re: Section 12.2.7
(66) In the left columns, the character "G" should be deleted.
Re: Alignment of wording
(67) In the draft, both words, "individual schedule" and "individual entry/entries", are used. I recommend to align the wording on your decision. The words are used at the following positions:
"Individual entry/entries"
Introduction 3.1, 3.2.1, 3.2.2, 3.3,4
Section 1.11, 3.2.2, 3.4.2, 3.5.3.1, 4.2.3, 5.2.3.2, 5.2.4.1, 9.3.1, 9.3.2, 9.3.4, 9.4.3, Legend in 9.4.3, 9.4.4, Legend in 9.4.4
"Individual schedule"
Section 1.2, 1.15, 10.7.1
Comments on the dreaft entries for individual cargoes
1 General comments on the letter dated on April 18
(1) Discussion on the outstanding issues
The item 3 of the draft terms of reference in DSC 5/WP.4 ANNEX 3, i.e., the outstanding issues which were identified in DSC 5/5/4 (paragraph 10) and require resolution, are as follows:
- operations on short international voyage;
- operation with open top barges;
- precautions to protect the ship's structure when loading very heavy cargo; and
- moisture variation on stock pile.
These issues were removed from the terms of reference of the C.G, at the plenary on the last day of DSC 5. Therefore, these issues should not be included in the discussion of the C.G. I consider that the C.G. should invite the relevant member States to submit the comments on these issues to the sub-committee directly for separate consideration. Regarding issues 1 to 3 on your letter, the C.G. should instruct the Finland to submit a paper to the Sub-committee directly.
(2) The proper distribution of heavy cargoes (outstanding issue No.4)
I am of the opinion that this issue should not be included in the discussion of the C.G., basically, by the above reason. By the way, SOLAS VI/5.3 is the requirement for stowage of heavy cargoes other than solid bulk cargoes. Heavy cargo and high density solid bulk cargoes should not be confused.
The precautions for high density cargoes are better to be included in the entries of relevant cargoes as to read as follows:
"Reference is made to Section 2 of this Code. As the density of cargo is extremely high, care should be taken to ensure that the cargo is evenly spread across the tank top to equalize the weight distribution. Do not pile up the cargo in the centre of the hatch during loading."
2 General comments on each item in individual entries
2.1 Cargo Name (Entry)
Re: "MINERAL CONCENTRATES"
(3) "MINERAL CONCENTRATES" is not appropriate as a Bulk Cargo Shipping Name. Therefore, I consider that the entry of "MINERAL CONCENTRATES" should be divided such as the entry for "MAGNETITE".
Re: "MINERAL CONCENTRATES"
(4) Synonyms should be expressed in a specific way and the explanation for the description should be made, for example as follows:
"CEMENT COPPER
Copper precipate
Note:
The Bulk Cargo Shipping Name is distinguished by capital letter. In addition ore or mineral names may be used to describe the same cargo. These names are in italics."
Except "METAL SULPHIDE CONCENTRATES BC No.035", all mineral concentrates in this Code are not liable to possess chemical hazards. Therefore, BCSN should be used for these cargoes in lieu of Proper Shipping Name.
Re: "MINERAL CONCENTRATES"
(5) The description "All known names of mineral concentrates are included in the following table but the list is not exhaustive" should be incorporated in Section 7 of the BC Code as to read as follows:
